Supreme Court Resolves Split Over Federal Inmates’ Habeas Rights

A provision of the Antiterrorism and Effective Death Penalty Act requiring federal courts to dismiss certain previously raised habeas corpus claims applies only to state prisoners’ applications, the US Supreme Court said Friday.

“AEDPA is replete with examples of Congress treating state and federal prisoners differently,” Justice Sonia Sotomayor wrote for the 5-4 court.

The decision resolves a six-to-three circuit split that the justices were eager to resolve over the extent of the law’s applicability.

Significant structural barriers resulted in the question presented in petitioner Michael Bowe’s case having a history of evading review.

Bowe pleaded guilty in 2008 to conspiracy to commit Hobbs Act robbery, attempt to commit Hobbs Act robbery, and discharging a firearm during and in relation to a “crime of violence” in violation of 18 U.S.C. § 924(c).

Although a series of subsequent Supreme Court decisions invalidated the grounds for his firearm conviction, the US Court of Appeals for the Eleventh Circuit said it couldn’t grant his request for authorization to pursue habeas relief because of the AEDPA.

Section 2244(b)(1) of the law says federal courts must dismiss a claim presented in “a second or successive habeas corpus application under section 2254” if it was presented in a prior application.

Although Section 2254 covers habeas corpus applications filed by state prisoners, the Eleventh Circuit is one of the six circuits that said it also applied to motions for habeas relief filed by federal inmates under 28 U.S.C. § 2255.

Three circuits said the law’s plain language states it only applied to state prisoners’ applications.

The government told the Supreme Court it agreed with Bowe’s reading of 2244(b)(1) and contested only the justices’ jurisdiction to hear the case.

Because the government didn’t dispute Bowe’s position on his core question, the court appointed Kasdin M. Mitchell of Kirkland & Ellis to argue in support of the Eleventh Circuit’s decision.

Justice Neil M. Gorsuch dissented, joined by Justices Clarence Thomas and Samuel A. Alito Jr. in full, and Justice Amy Coney Barrett in part.

Bowe is represented by the Roderick and Solange MacArthur Justice Center and the Southern District of Florida Federal Public Defender’s Office.

The case is Bowe v. United States, U.S., No. 24-5438, 1/9/26.